# Pre-audit preparation — LL144 and bias audits

Your bias audit is due and you do not know what the auditor will find.

One to two weeks: find what an independent auditor would flag, and fix it before they arrive.

1-2 weeks · $8K-12K

Scales with the number of tools and decision points in scope.

## Who this is for

- You use an automated tool anywhere in hiring or promotion and it falls under NYC Local Law 144.
- You have an audit scheduled and would rather find the problems first.
- A prior audit came back with findings and nobody has remediated them.

## Who this is not for

- You need the formal audit itself. That is performed by an independent auditor, by law — this engagement prepares you for it, fixes what they would find, and shortens their engagement and your bill.
- You want the result changed rather than the system fixed. That is not preparation, and it is not on offer.

## What you get

- A gap analysis against what an independent auditor will actually test.
- Data and instrumentation review: whether you can even produce the required impact ratios from what you currently log.
- Remediation of what the analysis finds, at the system level.
- Notice and disclosure mechanics implemented where the obligation requires them.
- A handover pack the independent auditor can work from, which shortens their engagement and your bill.

## How it runs

### Week 1: Gap analysis

What the auditor will test, what your data can currently support, and where the exposure is.

### Week 2: Remediation

Fix what was found, implement the notice mechanics, and assemble the pack the auditor will start from.

## Reported experience

- Annual: Independent bias audit required for automated employment decision tools
- $500-1,500: Per day, per violation, under the NYC penalty regime

## Evidence and limits



## Questions

### Can you run our bias audit?

No, by design. The law requires an independent auditor, and whoever built or hardened a system cannot certify it independently — a regulator would be right to object. This engagement prepares you for the auditor and fixes what they would find.

### Is the enforcement real?

The New York State Comptroller published a critical review of enforcement in December 2025 calling it ineffective, and the practitioner guidance since has pointed the same direction: expect tightening, not relaxation. Preparing during a quiet period is cheaper than remediating during a loud one.

### Who do we use for the formal audit?

You will get an introduction to independent auditors who do this properly. There is no referral fee in either direction, because that would compromise the independence the law is asking for.

Technical readiness, not legal advice. Counsel determines which obligations apply.

## Contact

[Discuss this engagement](mailto:n@nickcerutti.com) · [Pricing and terms](https://nickcerutti.com/pricing)

Canonical page: https://nickcerutti.com/services/bias-audit-prep